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2017 (12) TMI 1551
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....Shah Revenue by : Shri Purushottam Kumar ORDER C.N. Prasad (JM) 1. These two appeals are filed by the assessee against the orders of the Learned Commissioner of Income Tax (Appeals)-2, Mumbai dated 29.01.2015 for the Assessment Years 2011-12 and 2010-11 respectively. The only grievance in both these appeals is in respect of confirming the disallowance u/s. 14A r.w. Rule 8D(2)(iii). ....
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....nts Private Limited (supra). We observe that the Special Bench of the Delhi Tribunal held that only those investments are to be considered for computing average value of investments which yielded exempt income during the year. Therefore, respectfully following the said decision, we direct the Assessing Officer to compute the disallowance under Rule 8D(2)(iii) by considering only those investments ....